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1
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VERIFIED COMPLAINT
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EXTRACTED KEY WORDS
VIACOM PARTNERSHIP ARC COMCAST HTS GENERAL PARTNER PLAINTIFF OBLIGATIONS DUTIES COMPLAINT DEFENDANT HOME TEAM SPORTS NEGOTIATED BREACH PROVISION TAGALONG TRANSACTION COMCAST CORPORATION AFFILIATED REGIONAL COMMUNICATIONS INJUNCTIVE RELIEF WHEREBY COMCAST DOCUMENT PURSUANT NONDEFAULTING PARTNER TAG RIGHTS CONSUMMATING REGIONAL SPORTS NETWORKS TRANSACTION CONTEMPLATING NEGOTIATIONS CASTLE COUNTY MIDWEST SPORTS CHANNEL WILLFUL BREACHES |
IN AND FOR NEW CASTLE COUNTY
AFFILIATED REGIONAL
COMMUNICATIONS, LTD.
Plaintiff,
V i Civil Action No. 1%) bd-NC
VIACOM INC. and COMCAST
CORPORATION,
Defendants, i
HOME TEAM SPORTS LIMITED i
PARTNERSHIP,
1
Nominal Defendant. ) . .
_.. "- .
-1 -"
VERIFIED COMPLAINT
Plaintiff Affiliated Regional Communications, Ltd. ("ARC.`), by its undersigned
attorneys and upon knowledge as to itself and otherwise upon information and belief, states as
follows for its Complaint against Defendants:
NATURE OF THE ACTION
1. This is an action for, among other things, preliminary and permanent
injunctive relief, arising from an asset purchase agreement, dated June 30, 2000 (the "Asset
Purchase Agreement"), whereby Comcast Corporation agreed to purchase Viacom Inc's general
partnership interest in Home Team Sports Limited Partnership ("HTS" or the "Partnership") and
its interest in Midwest Sports Channel and Midwest Sports Channel Wisconsin (collectively,
"MSC"). By entering into the Asset Purchase Agreement, Viacom has committed egregious
breaches of its fiduciary and contractual duties to HTS' limited partner, ARC, in blatant
disregard of its obligations as the general partner of HTS. These willful breaches were
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